Long Term 2 (LT2) Surface Water Treatment Rule

Transcription

1 Long Term 2 (LT2) Surface Water Treatment Rule Round 2: What you need to know

2 Long Term 2 Enhanced Surface Water Treatment Rule Presentation Outline Introduction of the Rule - Why Cryptosporidium Federal Requirements Sampling Reporting Analysis and Round One Experience Laboratory Questions Round One Experience Regulators and Utilities Round Two Group Discussion 2

3 LT2 - Chronology SWTR (1989) SDWA Amendments (1996) DBP1 and IESWTR (1998) DBP2 and LT2ESWTR (2006) DBP3 and rtcr (Future) LT2 Purpose = to reduce pathogen (GI) illness

4 Introduction of the Rule History: Disinfection of drinking water is one of the major public health advances in the 20th century. 100 years ago, typhoid and cholera epidemics were reduced by disinfection. In the past 15 years, we found specific microbial pathogens, such as Cryptosporidium, which can cause illness, and are highly resistant to traditional disinfection practices. Disinfectants themselves can react with naturallyoccurring materials in the water to form byproducts, which may pose additional health risks. 4

5 Introduction of the Rule (cont) 1996 SDWA amendments Require EPA to develop rules to balance the risks between microbial pathogens and disinfection byproducts (DBPs) Stage 1 Disinfectants and Disinfection Byproducts Rule and Interim Enhanced Surface Water Treatment Rule (promulgated in December 1998) were the first phase in a rulemaking strategy. LT2 and the Stage 2 DBP Rule are the second phase of rules required by Congress. Strengthen protection against microbial contaminants, especially Cryptosporidium, and at the same time, reduce potential health risks of DBPs 5

6 Introduction of the Rule (cont) Purpose: To reduce disease incidence associated with Cryptosporidium and other disease-causing microorganisms in drinking water Improve public health protection 6

7 Introduction of the Rule (cont) Ensures that systems maintain microbial protection as they take steps to reduce the formation of disinfection byproducts Addresses the need for filtered public water systems (PWSs) with higher levels of source water Crypto contamination to provide additional risk-based treatment for Crypto beyond the IESWTR or LT1ESWTR requirements Addresses the need for unfiltered PWSs to provide risk-based treatment for Crypto to achieve equivalent public health protection with filtered PWSs Addresses the need for PWSs with uncovered finished water storage facilities to take steps to reduce the risk of contamination of treated water prior to distribution to consumers 7

8 Why Cryptosporidium? Cryptosporidium oocysts are highly resilient and can survive filtration and disinfection processes Resistant to chlorine One of the most common causes of waterborne disease in humans in the U.S. Gastrointestinal illness, which may be severe and potentially fatal to at risk populations Methodology also reports Giardia 8

9 Why Cryptosporidium (cont)? 1993: Cryptosporidium outbreak in Wisconsin 400,000+ illnesses 50+ deaths 2006: Five states reported outbreaks associated with recreational water use. 2008: Study on 160 public swimming pools from 2 metro Atlanta counties showed 13 were positive for one or both of the contaminants (Crypto and/or Giardia). 9

10 Benefits & Costs Benefits EPA estimates that full compliance with LT2 will reduce the incidence of gastrointestinal illness caused by ingestion of Cryptosporidium by: ~ 90, million cases per year ~ premature deaths Monetized benefits ~$253 million - $1.4 billion Costs EPA estimated range from ~ $92-$133 million. Public water systems bear ~99% of costs, states incurring ~1% Average annual household cost estimated to be $1.67-$2.59/yr. 10

11 LT2 REQUIREMENTS Federal (USEPA) Requirements of the Rule 11

12 Federal (USEPA) LT2 Round One Report to EPA USEPA Laboratory Certification LT2 Round Two Report to the State State by State Lab Certification Criteria CA = ELAP approval, NV = Federal List Or EPA in some States Or NELAC in some States 12

13 Federal (USEPA) Applies to all public water systems using surface water sources or GWUDI sources Compliance deadlines are based on number of people served Divided into four schedules 13

14 LT2 Monitoring Requirements Turbidity (Certified Operator) E.Coli (State Certified Lab) Crypto (EPA/State Approval Lab) EPA 1622 (Crypto only) EPA 1623 (EnviroCheck, EasySeed) EPA (AccuSpike, Pellet Wash)

15 Applicability Population Served > 100,000 50,000 99,999 10,000 49,999 <10,000 <10,000 (Schedule 1) 1 (Schedule 2) 1 (Schedule 3) 1 (Schedule 4) 1,2 (Schedule 4) 1,3 Report Sampling Schedules & Locations For Round II Source Water Monitoring January 1, 2015 July 1, 2015 July 1, 2016 July 1, 2017 January 1, 2019 Begin Round II Source Water Monitoring April 1, 2015 October 1, 2015 October 1, 2016 October 1, 2017 April 1, 2019 Report Bin Classification & Supporting Data from Round II Monitoring October 1, 2017 April 1, 2018 April 1, 2019 April 1, 2020 October 1, Schedule is defined by the largest system in your combined distribution system 2 Applies to filtered system (E. coli only) 3 Applies to unfiltered systems and those filtered systems that exceed the E. coli trigger or do not monitor for E. coli (Crypto) 15

16 Requirements of the Rule Filtered water systems must reduce source water Crypto levels by 99% (2-log) Additional treatment is necessary for higher risk systems Filtered systems with high levels of crypto All unfiltered water systems Understanding log removal Percent of Crypto that is removed or inactivated by treatment or other measures 16

17 Requirements of the Rule (cont) Log Removal Example 1 System A (unprotected) System B (pristine) Source Water 100,000 Crypto oocysts 100 Crypto oocysts Crypto Reduction 2-log removal /inactivation (99%) 2-log removal /inactivation (99%) Finished Water 1,000 Crypto oocysts 1 Crypto oocyst Both systems provide the same level of Crypto removal/inactivation, but System B provides higher quality finished water 17

18 Requirements of the Rule (cont) Log Removal Example 2 System A (unprotected) System B (pristine) Source Water 100,000 Crypto oocysts 100 Crypto oocysts Crypto Reduction 5-log removal /inactivation (99.999%) 2-log removal /inactivation (99%) Finished Water 1 Crypto oocysts 1 Crypto oocyst Both systems provide the same public health protection, but System A must provide a higher degree of treatment to get there 18

19 Requirements of the Rule (cont) Log Removal Example 3 System A System B Source Water 1,000 Crypto oocysts 1,000 Crypto oocysts Crypto Reduction 3-log removal /inactivation (99.9%) 2-log removal /inactivation (99%) Finished Water 1 Crypto oocysts 10 Crypto oocyst System A is able to produce higher quality finished water than System B, even though Systems A and B have the same source water Crypto level 19

20 Requirements of the Rule (cont) Bin and Treatment Overview Filtered Filtered PWSs will be classified in one of four treatment categories ( bins ) based on the results of the source water Crypto monitoring Bin classification determines the degree of additional Crypto treatment, if any, the filtered PWS must provide Occurrence data indicate that most filtered PWSs will be classified in Bin 1, which carries no additional treatment requirements PWSs classified in Bins 2, 3, or 4 must achieve an additional 1.0- to 2.5-log of treatment (i.e., 90 to 99.7 percent reduction) for Crypto over and above the 2-log removal currently provided 20

21 Requirements of the Rule (cont) Bin and Treatment Overview Unfiltered Unfiltered systems treatment requirements are based on the results of their initial source water monitoring: Unfiltered systems with a mean Crypto level of 0.01 oocysts/l or less must provide at least 2-log Crypto inactivation Unfiltered systems with a mean Crypto level of greater than 0.01 oocysts/l must provide at least 3-log Crypto inactivation This must be accomplished using a minimum of two disinfectants 21

22 Requirements of the Rule (cont) Bin Classification For PWSs that are: *** required to monitor for Cryptosporidium * * * serving fewer than 10,000 people and NOT required to monitor for Cryptosporidium 1 With a Cryptosporidium bin concentration of The bin classification is... less than oocysts/l Bin oocysts/l or higher, but less than 1.0 oocysts/l 1.0 oocysts/l or higher, but less than 3.0 oocysts/l Bin 2 Bin oocysts/l or higher Bin 4 NA Bin 1 22

23 Calculating Risk Bin Classification If collecting monthly for 2 years Bin classification is calculated by averaging each 12 month period over the 2 years (April 2015-March 2016, May 2015-April 2016, etc) Highest 12 month average would be used to determine bin classification If collecting twice monthly for 2 years Average all 48 samples from the 2 year period 23

24 Calculating Risk Bin Classification Month Example 1: Collecting 1 sample monthly for 2 years. Highest 12 month average would be used to determine bin April May June July August Sept. Oct. Nov. Dec. Jan. Feb. March classification 2015 Oocysts Volume filtered in liters Month April 2016 May June July August Sept. Oct. Nov. Dec. Jan Oocysts Feb. March Volume filtered in liters Average for April 2015-March 2016 = 6 oocysts/ L = oocysts/l Highest Average is Oct Sept = 10 oocysts/ 124.5L = oocysts/l (BIN 2) 24

25 Calculating Risk Bin Classification Month Example 2: Collecting twice monthly for 2 years. Average all 48 samples from the 2 year period April 2015 May June July August Sept. Oct. Nov. Dec. Jan Oocysts 0/0 0/0 0/1 1/2 2/1 0/0 0/0 0/0 0/0 0/0 0/0 0/1 Feb. March Volume filtered in liters 10/10 10/10 10/ /10 11/ /10 10/ /10 10/10 10/10 10/ /11 Month April 2016 May June July August Sept. Oct. Nov. Dec. Jan Oocysts 0/0 0/0 1/3 3/2 2/1 1/0 0/0 0/0 0/0 0/0 0/0 0/0 Feb. March Volume filtered in liters 10/10 10/ / /10 10/ /10 10/ / /10 10/10 10/10 10/10 Average for all 48 samples = 21 oocysts/ 489 L = oocysts/l (Bin 1) Difference in cost of additional testing versus cost of additional treatment for Bin 2 classification is significant! 25

26 Calculating Risk Bin Classification Additional Crypto treatment required according to current Crypto oocyst concentration: 26

27 LT2 REQUIREMENTS - CA/NV CA/NV Requirements of the Rule 27

28 LT2 REQUIREMENTS - CA/NV Reporting Results Lab or System? All source water samples taken under the LT2 rule must be reported to your respective state agency. The system or the laboratory may submit the source water monitoring data to the state agency. The system will need to review and approve the source water monitoring data before it is submitted to the state. The PWS is ultimately responsible for making sure the lab reports the monitoring data. 28

29 LT2 REQUIREMENTS - CA/NV Forms. EPA states that systems must report LT2 monitoring to the state no later than 10 days after the end of the first month following the month when the samples were collected (e.g., a system that collects samples in October 2015 must report that data no later than December 10, 2015). Data must be reported monthly. NV LT2 reporting No electronic reporting. Will be modifying current forms and process to accommodate LT2. CA LT2 reporting Electronic reporting via State Write 29

30 Reporting Components Cryptosporidium sample: PWS ID Facility ID Sample collection date Sample type (field or matrix spike) Sample volume filtered (L), to nearest ¼ L Was 100% of filtered volume examined, Y/N Number of oocysts counted 30

31 Reporting Continued E. coli samples: PWS ID Facility ID Sample collection date Analytical method number Method type Source type (flowing stream, lake/reservoir, GUDI) E. coli/100 ml Turbidity 31

32 Reporting Continued For matrix spike samples, systems must also report the sample volume spiked and estimated number of oocysts spiked. For samples in which less than 10 L is filtered or less than 100% of sample volume is examined, systems must also report the number of filters used and the packed pellet volume. For samples in which less than 100% of sample volume is examined, systems must also report the volume of resuspended concentrate and volume of this re-suspension processed through immunomagnetic separation. 32

33 LT2 REQUIREMENTS - CA/NV Sample Plans Sampling plans due dates are established by a system s schedule. Systems serving 100,000 or more sample the earliest and are required to submit their sampling schedule to the state by January 1, 2015, with sampling to begin during the month of April

34 LT2 REQUIREMENTS - CA/NV Schedule 1-4 Population Served 1 100,000 or more served 2 50,000 to 99,999 served 3 10,000 to 49,999 served 4 Less than 10,000 served Sampling for Cryptosporidium, E. coli, turbidity-24 months Cryptosporidium, E. coli, turbidity-24 months Cryptosporidium, E. coli, turbidity-24 months SAMPLING PLAN DUE to CA/NV SAMPLING TO BEGIN E. coli-12 months

35 Sampling Where do I collect my sample? Systems must submit a description of their sampling location to the State at the same time as the sampling schedule is required to be submitted. Systems must collect source water samples (crypto, E. Coli and turbidity) prior to any chemical treatment. Systems that recycle filter backwash water must collect source samples prior to the point of filter backwash addition. 35

36 Sampling Coordinate with your Laboratory Crypto and E. Coli sample analysis must be performed at EPA or State approved laboratories Crypto samples must be sent to a lab certified by ELAP for LT2 Crypto. Receipt at lab within (generally) <24 hours (E Coli), <72 hours (Crypto) <20 degrees C, confirm laboratory hours/days of operation (typically M-Th) 36

37 Sampling What equipment and instructions provided? Field filtering vs 10L Bulk Water Collection Envirochek TM Envirochek HV Capsules TM Filta-Max Filter 37

38 LT2 Sample Collection 1. Flush (2-3 min) until turb/temp stable 2. Fill Cubitainer and Ship (after flush) 1. Connect Sample Unit without filter 2. Flush (2-3 min) until turb/temp stable 3. Install Filter 4. Open Tap, Bleed out air & adjust flow/pressure 5. Turn off after 10 liters 6. Remove outlet tubing and drain 7. Disconnect inlet tubing, seal capsule, bag, chill and ship

39 Lab Filtration Potential for Additional Fees 39

40 Sample Elution 40

41 Centrifugation 41

42 Centrifugation 42

43 Pellet Size Potential for Additional Analytical Fees 43

44 Vortex 44

45 IMS 45

46 IMS cont. 46

47 IMS cont. 47

48 IMS cont. 48

49 Reading Slides 49

50 Under the Microscope Multiple Cryptosporidium Multiple Giardia 50

51 LT2 Round 1 Scheduling Sample Collection Reporting and DCTS Quality Control Laboratory Attrition 51

52 Scheduling - Round 1 All schedules and sampling plans had to be approved by EPA EPA understaffed and fell behind approvals quickly Scheduling guidance and training was unclear early Schedules were not agreed to by laboratories Many labs became over capacity Some PWS were without a lab 52

53 Sample Collection Round 1 Sample temperature issues Bulk samples > 20 degrees C Filters frozen Missed matrix spikes Shipping of E. coli samples Missed collection dates 53

54 Reporting & DCTS Round 1 Data Control and Tracking System (DCTS) All data entered manually in web forms Frequent crashes Very slow when operational Lab could not report results in oocysts/liter to client Created confusion for client Made bin calculation even more confusing 54

55 Quality Control Round 1 Matrix Spikes Average recoveries from 25 to 50% No recovery requirements High turbidity samples Some samples took 6-8 hours to read slides Matrix spike may have results of 0% 55

56 Laboratory Attrition Round 1 48 labs on EPA approved lab list Municipal labs State labs Commercial labs Several dropped out or were dropped Lost analysts Approval revoked Too few samples High materials cost 56

57 Resources & References LT2 Rule Cryptosporidium & E. coli Sample Collection Recommendations Pocket Guide f Parasites Cryptosporidium Environmental Health Services (EHS) Cryptosporidium, Cryptosporidiosis 57

58 Thank you Monica Van Natta Account Manager Eurofins Eaton Analytical